Monitoring and Oversight Standards and Guidelines
Table of Contents
1.Standard
2.Background
3.Purpose
4.Oversight
5.Quality Improvement Reviews
6.Monitoring Plan
6.1.Areas of Review – Board Monitoring and Oversight
6.2.Area of Review - Quality Improvement Reviews
7.Operations Monitoring
7.1Risk Assessment
7.2Scheduling
7.3Participant Record System Review
7.4Desk Review
7.5Entrance Interview
7.6Site Visit
7.7Exit Interview
7.8Reporting and Corrective Action
8.Equal Opportunity and Accessibility Reviews
8.1.Scope
8.2.Risk Assessment
8.3.Scheduling
8.4.Service Accessibility Review
8.5.Physical Accessibility
8.6.Reporting
8.7.Corrective Actions
8.8.Sanctions
9.Financial Monitoring
9.1.Pre-award/Fiscal Integrity Review
9.2.Annual Financial Monitoring
9.3.Risk Assessment
9.4.Financial Aid Billing Monitoring
9.5.Special Reviews
9.6.Audit Resolution
9.7.Financial Monitoring Reports
10.Reporting
10.1.Contractor Internal Monitoring Reports
10.2.Performance, Production and Financial Accountability
10.3.Contractor Performance and Production
11.Process Improvement
11.1.Resolution
11.1.1.H-GAC Monitoring
11.1.2.Grantor Agency Monitoring
11.1.3.Sanctions
12.Fraud and Criminal Activity
1.Standard
Board staff reviews all Workforce Solutions system operations, contractors and projects to ensure effective and efficient service, proper use and safeguard of public funds, and compliance with system standards and guidelines, contractual requirements, and federal/state laws, regulations, and administrative directives.
2.Background
The Gulf Coast Workforce Board is the region’s workforce development board with planning and oversight responsibility for federal workforce dollars and service in the 13-county Gulf Coast area. Texas House Bill 1863 created the state’s workforce system, including the Texas Workforce Commission, the Texas Workforce Investment Council, and the regional workforce development boards in 1995.
The Gulf Coast Workforce Board, organized in 1996 and certified by the Governor of Texas in January 1997, selected the Houston-Galveston Area Council, the region’s council of governments, as its administrative and fiscal agent. H-GAC supports the workforce board in its planning and oversight activities, administers and accounts for all workforce dollars coming into the region, procures contractors to operate the Board’s operating affiliate Workforce Solutions, and reviews all operations for quality and compliance with applicable laws, rules and regulations.
Board staff,as well as contract consultants, monitor Workforce Solutions’ operations, including the funds from the Workforce Innovation and Opportunity Act, Child Care and Development Block Grant, Temporary Assistance to Needy Families, Supplemental Nutrition Assistance, Wagner-Peyser Act, the Trade Act, adult education funds (authorized through Title II of the Workforce Innovation and Opportunity Act, for which H-GAC assumed administrative and fiscal responsibility beginning in 2015)and any other current federal or state funds active for our region.
Monitoring activitiesensure that contractors operating Workforce Solutions and related projects adhere to the Board’s standards and guidelines and federal/ state laws, rules, policies and procedures. Monitoring is a part of the Board’s responsibility to"develop state/local strategic planning, evaluation and accountability for the state's workforce development programs and activities."
3.Purpose
The purpose of oversight and monitoring is to ensurethe Gulf Coast Workforce Board's system, contractors, and H-GAC are operating a high-quality system in compliance with the Board’s standards and guidelines; all applicable laws and regulations; agreements with federal or state grantor agencies; and appropriate administrative directives.
Board staff monitors evaluateoperational and financial compliance on a periodic basis. The results are used to ensure the system operates effectively to achieve the Board’s stated results and to safeguard the expenditure of public funds. Boardstaff report on monitoring results to the Workforce Board Audit Monitoring Committee and this committee chair reportsat each Board meeting, summarizing findings and recommendations.
4.Oversight
The Gulf Coast Workforce Board uses monitoring results in its oversight of the region’s workforce system and contractors. The Board also uses monitoring information, reports and results in making funding decisions and during procurements. The Workforce Board informs chief elected officials, represented by the H-GAC Board of Directors, of its findings and recommendations, and together the Workforce Board and H-GAC Board of Directors authorize contracts and system operations.
The Gulf Coast Workforce Board performs its oversight as a whole and does not delegate these responsibilities to any committee. The Gulf Coast Workforce Board has an Audit and Monitoring Committee that reviews the work of the monitors and reports out to the entire board.
5.Quality Improvement Reviews
The Gulf Coast Workforce Board, in its desire to be a world class workforce system,expects quality from its contractors inthe way results are achieved. In support of quality improvement,Board staff and contractor staff will conduct a separate review from the Board’s monitoring and oversight compliance review.
These reviews are an opportunity to identify quality initiatives, identify challenges, and opportunities for improvement within the workforce system. It will also increase quality and ensure we are providing the best service for both our employer and applicant customer.
The reviews will be focused on quality and results will be reported to the contractor by Board staff and to the Board through the Audit and Monitoring Committee.
6.Monitoring Plan
The monitoring plan includes:
- a schedule or timetable for monitoring all units of the regional workforce system, including Workforce Solutions contractors, special projects contractors, adult education contractors, and system processes;
- the type of review planned for each (on-site review, comparativefinancial analysis, desk review, quality improvement or other type of appropriate review); and
- the estimated time budgeted for each review.
The Quality Manager ensures Board staff the quality improvement team,and financial monitoring contractors use standard written monitoring processes to assess:
- the system and contractor’s delivery of high-quality, effective service that achieves the Board’s results
- contractors’ compliance with Workforce Solutions standards and guidelines, federal/state laws, regulations and other authoritative pronouncements;
- contractors’ compliance with contractual requirements; and
- proper expenditure of, and accurate accounting for, federal/state funds.
Monitors review:
- any new contractor before, or as quickly as can be reasonably scheduled after, initiation of a contract;
- each system unit and each contractor at least once eachyear;
- Board administrative operations at least once everyyear;
- summerjobs projects with assistance of additional staff each summer; and
- other workforce projects as appropriate.
Monitors may expand the review of a unit or contractor beyond the scope of the standard monitoring program to ensure activities and systems are consistent with the intent of the applicable law.
H-GAC expects its staff members, consultants and the quality improvement team to carry out reviews in a professional manner and to accommodate special needs or schedules of contractor personnel and customers.
6.1.Areas of Review – Board Monitoring and Oversight
During each program year, H-GAC will designate specific areas for special attention. Compliance reviews include, at a minimum, the following items:
- Workforce Solutions standards and guidelines; policies and procedures
- basic contract and grant requirements
- procurement, including contract award process
- property
- financial systems and administrative records
- budgets, allowable costs, cost allocation, and cost limitations
- participant eligibility
- participant record keeping systems, tracking and reporting
- specific legislative and regulatory program operation requirements
- contract program design requirements
- grievances, investigations, and grievance hearings
- equal opportunity and accessibility standards
- management information systems processes, standards and requirements
- personnel standards and practices
- compliance with Federal employment standards
6.2.Area of Review - Quality Improvement Reviews
Areas to be observed, as applicable, during the quality review include:
- Customer service and customer satisfaction
- Class observationsand facility reviews
- Communication and collaboration
- Performance and production strategies
- Employer service
- Quality applications
- Quality referrals
- Quality job postings
- Improving direct placements
- Strategies to serve special populations
- Other areas of quality identified in the scope of work
- Staff
- Training
- Staffing
7.OperationsMonitoring
7.1Risk Assessment
At the beginning of each program year, Board staff performs an annual Risk Assessment Survey to determine the order of scheduling subcontractor monitoring visits. The risk assessment includes an analysis of the following areas for each unit and contractor:
- Changes in scope or responsibility from the previous year
- Staff turnover
- Timeliness and accuracy of reports submitted
- Fiscal integrity review
- Monitoring report rating
- Prior year continuing findings
- Number of complaints received
- Compliance with policies, rules and regulations
- Performance Achievements
- Number of Customers
- Contract Manager input
Board staff assigns a risk level to each unit and contract based on the scores from the assessment.
7.2Scheduling
The Quality Manager develops theschedule for monitoring visits anda courtesy notification will be sent to the appropriate parties before each scheduled review when applicable. Schedule is subject to change if circumstances warrant.
7.3Participant Record System Review
This will be an unannounced visitwithout an entrance or exit interview. Information maintained in electronic files will be reviewed to determine its integrity. The review is performed electronically using eligibility documentation contractors submit to their respective tracking units and the Financial Aid Support Center. Board staff conducts these reviews at least once each quarter and may increase the frequency or scope of the review based on findings from previous reviews.
Board staff monitors review customer data in the appropriate computer systems including but not limited to: The Workforce Information System of Texas (TWIST), WorkInTexas (WIT), DocuWare, Financial Aid Management System (FAMS),and Texas Educating Adults Management System (TEAMS).
Board staff issues written reports for each of these reviews to each responsible contractor. Board staff may conduct follow-up reviews electronically or on-site at the respective unit or contractor.
7.4Desk Review
In preparation for an on-site visit, monitors review the status of the contract to be monitored with the Contract Managerand other appropriate department staff members to determine the scope of the review.
The desk review includes:
- Discussion with H-GAC contract managers and other H-GAC workforce staff on issues or problems;
- Review of the current year contract document, including the budget, staffing summary, and scope of work;
- Review of the previous year monitoring and financial monitoring report, noting any findings and evidence of resolution;
- Discussion with EO Officer regarding previous equal opportunity and accessibility review findings;
- Review of contract expenditures to date against budget; and
- Current period performance and production data for the contract.
Monitors assigned to an on-site visit prepare the plan for the review and discuss the plan with the Quality Manager before conducting the review.
7.5Entrance Interview
At the beginning of a site visit, monitors will conduct an entrance interview with the appropriate representatives of the contractor. In the interview, the monitors will describe the scope and process of the review, the expected timetable for the review, and required information and access to individuals and records. The monitors will also discuss and arrange appropriate workspace, monitors’ working hours and access to office equipment and telephones.
7.6Site Visit
Monitors will ensure that they are professional in dress and action while on-site. They will also be aware of the contractor’s time and make requests at the entrance to expedite the review.
The monitoring team will notify the Quality Manager of findings as they occur. The on-site manager will be notified before the exit interview. We always give a contractor the opportunity to provide documentation and explanations for findings during an on-site visit. It is always possible that monitors will overlook documentation or it may be maintained in a different location.
While on-site the quality assurance regional monitoring team will also perform the following functions related to equal opportunity: 1) verify the implementation of corrective actions reported by the contractor for previous equal opportunity and accessibility review findings, 2) observe a demonstration of assistive technology and auxiliary aids on the matrix provided by the EO Officer, and 3) ensure required posters are displayed appropriately. The results will be reported to the Equal Opportunity Officer who will determine if further action is warranted.
7.7Exit Interview
After completing a visit, and before leaving the site, the monitors will provide an exit interview with appropriate representatives of the contractor.
Monitors will prepare the exit agenda and submit it to the Quality Manager before the exit interview to allow the monitors time to discuss potential findings with the Quality Manager.
In the exit interview, the monitors will shareareasof non-compliance found and may offer comments and suggestions on operations.
Monitors will not direct contractor staff, will not provide a preliminary rating and will not provide technical assistance. Ifa requestfor technical assistance is made by the contractor, monitors will notify the Quality Manager and the contractor’s assigned Contract Manager.
Quality Improvement Reviews
The quality improvement team will provide the information from the review to the Quality Manager. The information will be included in the annual report issued.
7.8Reporting and Corrective Action
Section 10 of these Standards and Guidelines describes the reporting process. Section 11 describes the process for corrective action resulting from monitoring.
8.Equal Opportunity and Accessibility Reviews
H-GAC conducts equal opportunity and accessibility reviewsin accordance withstate and federal accessibility standards as well asguidelines issued by the applicable funding source andthe Texas Workforce Commission.
8.1.Scope
At least once a year H-GAC will evaluateservice accessibility and physical accessibility for the following, as appropriate: H-GAC offices,contractor administrative offices, Workforce Solutions service points and support units, Adult Education providers, andspecial project contractor sites.
8.2.Risk Assessment
At the beginning of each program year, the Equal Opportunity Officer will perform an annual risk assessment to determine the scheduling order for equal opportunity and accessibility reviews.
The risk assessment will take into consideration results from previous years’ reviews, facility additions or changes, and discrimination complaints.
8.3.Scheduling
Based on the results of the risk assessment, the Equal Opportunity Officer will develop a schedule for equal opportunity and accessibility reviews. The schedule is subject to change if circumstances warrant.A courtesy notification will be sent to appropriate parties before each scheduled review.
8.4.Service Accessibility Review
The Equal Opportunity Officer will conduct service accessibility reviews using the WIOA Section 188 Checklist, which includes, as appropriate,an examination of:
- equal opportunity policy dissemination;
- demographics of customers served by sex, ethnicity/race, age and disability status;
- the results of each entity’s annual review of their job descriptions, training plans, contracts, assurances, policies, procedures, and other similar documents to ensure they are not discriminatory;
- physical retention of medical and disability related information;
- discrimination complaint processing;
- accommodation request processing; and
- corrective actions/sanctions.
8.5.PhysicalAccessibility
The Equal Opportunity Officerwill also conduct physical accessibility reviews using a checklist based on the 2010 Americans with Disabilities Act (ADA) standards and the 2012 Texas Accessibility Standards (TAS). This review is aimed at ensuring locations are architecturally barrier free and will include asking for a demonstration of allavailable assistive technology and auxiliary aids.
8.6.Reporting
No later than thirty (30) working days following the completion of the equal opportunity and accessibility review, the Equal Opportunity Officer will issue a report that identifies, at a minimum: (1) the name of the contractor reviewed, (2) the site(s) reviewed, (3) the date of the review, (4) the date the report was written, (5) the names of individuals interviewed,(6) findings from the review, (7) recommendations for corrective actions, (8) the response due date and (9) next steps. The report will be sent to Contractor management staff and the manager of the site reviewed, with copies to the Director of Human Services, Workforce System Program Manager, Quality Manager, and Contract Manager.
8.7.Corrective Actions
All correspondence related to equal opportunity and accessibility reviews should be submitted to the Equal Opportunity Officer.
Contractors are required to submit corrective action plans, including a timetable for completion, by the deadline stated in the report. Responses are reviewed and feedback provided. Proof of completing corrective actionsshould be submitted within the agreed upon timeframe, unless an extension is granted. Once proof of completion has been accepted for all findings, a final report will indicate the date of resolution.
Equal opportunity and accessibility review reports, corrective action plans, and ongoing correspondenceare maintained for use in follow-up activities and future reviews.
Note:Corrective action plans involving any type of expenditure of funds must be approved by the Equal Opportunity Officer prior to purchase or service authorization.
8.8.Sanctions
In the event the Contractor is unable or unwilling to implement the approved corrective action plan, the Board may institute sanctions in accordance with its sanctions policy as listed in the Contract Management Policies and Procedures.
9.Financial Monitoring
Gulf Coast Workforce Board uses contracted fiscal monitors procured through an RFP process. We contract with CPA firms experienced in government accounting procedures. Proposals are reviewed and analyzed by Workforce Board staff and H-GAC financial staff. References are checked and the H-GAC Board of Directors approves the contract(s).